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III IIIIIIIIIIIIIIII <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Depdrlment of N,lural ResourCeS <br />I SI 1 Sherman 51., Room 215 <br /> <br />Denver, Cnlorarlo BO203 Ih~~ <br /> <br />Phone: (303)Afi6-3567 I <br />FA%: 13031 A32-A 106 <br /> DEPARTMENT OF <br /> NATURAL <br /> RESOURCES <br /> Ruy Romer <br /> Governor <br />only z9, 1997 lames 5. Lochhead <br /> Ececuuve Director <br /> Michael B. Long <br /> Division Director <br />Mr. Michael Altavilla <br />Seneca Coal Company <br />P.O. Drawer D <br />Hayden, CO 81639 <br />RE: Seneca II Mine (C-80-005) <br />TR-31; Topsoil Management Plan <br />Deaz Mr. Altavilla, <br />The Division of Minerals and Geology received yow technical revision application (TR-31) <br />addressing the topsoil management plan at the Seneca II Mine (C-80-005). This technical <br />revision is in response to the 1995 Midterm Review and the 1997 Permit Renewal, stipulation 34 <br />to the permit. <br />Seneca Coal Company proposes a range in topsoil replacement depth from zero inches to 14 <br />inches at the Seneca II Mine. The Division does not believe that is appropriate to approve azeas <br />of the mine without any topsoil. The Seneca II permit currently requires a topsoil replacement <br />depth of 12 inches. Prior to reducing the overall topsoil depth, Seneca should look at other <br />management alternatives such as importing topsoil, the use of rock piles and less topsoil for <br />shrub reestablishment areas. Based on results of reclamation of pre-law disturbance at the <br />Seneca Mine where topsoil was not salvaged and redistributed, the Division does not believe that <br />reclamation without any topsoil is acceptable at the Seneca II Mine. The following questions <br />pertain to this issue and need to be addressed by Seneca prior to approval of the revision; <br />In May of 1996, Seneca surveyed the topsoil piles and remaining areas to be topsoiled at <br />the Seneca [[ Mine. At that time, Seneca determined that 607.4 acres (minus the <br />remaining roads) require topsoil. The new plan states that 497 acres will be topsoiled. <br />Taking into account the 90 acres that Seneca proposes as a subsoil substitute, there is a <br />20.4 acre discrepancy between the estimated acreage in 1996 and what is noted in this <br />revision. Please clazify this discrepancy with the Division. <br />